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Facts of the Case:
The case revolves around a law student (‘X’) from Maharashtra National Law University (MNLU) who was expelled after being found guilty of “repeated” sexual harassment of female students by the university’s Internal Committee (IC). This is the second round of litigation initiated by the student, following his challenge to the university’s decision to expel him for an indefinite period. The student’s expulsion was based on a report by the IC dated May 20, 2023, recommending disciplinary action.
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Prior to this, ‘X’ had already faced disciplinary measures, including expulsion from the university hostel in June 2022. Despite the expulsion, he was allowed to sit for his ninth and tenth semester exams, though the university withheld his results pending the resolution of his legal challenge.
The student argued that his indefinite expulsion from the university would effectively result in “academic death,” depriving him of the opportunity to complete his legal education.
Contention of the Petitioner (Student ‘X’):
Petitioner challenged the university’s decision to expel him for an indefinite period. And argued that the indefinite expulsion was harsh and disproportionate to the misconduct, leading to what he termed “academic death.” He claimed the decision would deprive him of the chance to complete his degree, effectively terminating his academic and professional career.
Contention of the Respondents (University and Vice Chancellor):
They defended the expulsion, citing the IC’s report and the need to maintain institutional discipline. They in their argument highlighted the seriousness of the sexual harassment findings, justifying their strict disciplinary action. And emphasized that the expulsion was a legitimate response to the misconduct to uphold the safety and integrity of the academic environment.
Court’s Observations:
The court acknowledged that while the student was guilty of serious misconduct, the punishment of indefinite expulsion was disproportionate. Referring to prior judgments, including the Anant Narayan Mishra Vs. Union of India and Others, (2019 AHC 201145) case and rulings on the principle of proportionality in student discipline, the court stressed that punishments should not be unduly harsh. Citing the Supreme Court’s doctrine of proportionality, the court emphasized the need to balance institutional discipline with the individual’s right to education.
The court noted that indefinite expulsion would essentially result in “academic death” for the student. This would permanently halt his legal education and have severe consequences for his academic life.
The court highlighted that even after expelling the petitioner, the Vice Chancellor allowed him to take his final exams but withheld the results pending the court’s decision. This demonstrated that the student was academically competent and nearing the completion of his degree.
The court declined to remand the case back to the Vice-Chancellor for re-consideration, reasoning that it would only lead to further litigation. Both the complainant (‘Y’) and the student (‘X’) should be allowed to focus on their academic pursuits without further distractions.
Court’s Order:
The court upheld the expulsion based on the IC’s report and the seriousness of the student’s misconduct. The expulsion was justified but should not extend indefinitely.
The court ruled that the expulsion should last only until the end of the academic year 2024-25, rather than being for an indefinite period. The court ordered the student to engage in community service under the guidance of the Vice-Chancellor for the duration of this period.
The university was directed to release the student’s ninth and tenth semester results upon completion of his community service at the end of the academic year 2024-25. The student was ordered to refrain from any interaction with the complainant (‘Y’) during his community service.
The court advised the Vice-Chancellor to consider recommendations made by the IC to improve university policies, including a review of event venues to prevent the serving of alcohol at university functions.
